Press Release

Haynes Boone Secures Victory that Revives Prisoner’s 8th Amendment Sleep-Deprivation Case

March 25, 2024

Haynes Boone prevailed in the U.S. Court of Appeals for the Fifth Circuit in a decision that brings the Fifth Circuit's Eighth Amendment law in line with U.S. Supreme Court precedent.

Michael Garrett, an inmate in Texas for more than 30 years, challenged the Texas Department of Criminal Justice’s (TCDJ) sleep schedule at the Huntsville prison where he is incarcerated, which allows only 3.5 hours of sleep per night and includes frequent interruptions. Despite persistent pleas to prison officials about the severe health risks posed by chronic sleep deprivation, he was repeatedly ignored. Haynes Boone, which provided pro bono legal services to Garrett, argued the schedule posed a substantial risk of serious health problems and violated Mr. Garrett’s constitutional rights.

The appeals court vacated a district court decision rejecting Mr. Garrett’s complaint, and it clarified Fifth Circuit law to align it with binding U.S. Supreme Court precedent. The court then sent Mr. Garrett’s case back to the district court to use the correct legal standards.

The Fifth Circuit’s opinion decisively addressed two key legal errors made by the district court — errors also made in other courts throughout the Fifth Circuit. First, the district court incorrectly required Mr. Garrett to prove his sleep deprivation caused existing health problems, rather than simply demonstrate a substantial risk that sleep deprivation could cause him serious harm. Second, the district court considered the TDCJ’s penological interests to justify its prison sleep schedule.

The Fifth Circuit clarified that TDCJ’s penological interests are irrelevant. The court also notably acknowledged that it applied the wrong standard in multiple of its own unpublished decisions and district courts throughout the Fifth Circuit made similar errors.

“This ruling marks an important victory and key step in Mr. Garrett's decade-long quest for an ordinary night’s sleep,” said Associate Chris Knight, who argued the case before the Fifth Circuit in December. “The court’s decision is also important because it aligns with U.S. Supreme Court precedent and abrogates multiple decisions that had applied the incorrect standard. We’re proud to be part of it.”

The Haynes Boone team also included associates Chance Fletcher and Wes Dutton.

Described by Chambers USA 2023 as “a destination appellate practice” and praised as being “pretty widely recognized as number one,” Haynes Boone’s Appellate Practice Group received the highest ranking in Texas in Chambers USA (Chambers and Partners), as one of only three firms with a Band 1 rating in Texas in the 2023 directory.

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